Justia Constitutional Law Opinion Summaries

After being released from the penitentiary earlier than permitted by the statutory minimum sentence for his crime, Appellant was convicted of another crime, and his sentence was enhanced by his prior conviction. He argued on appeal that his prior judgment of conviction was void because it imposed confinement for less time than the statutory minimum and that, because it was void, it should not have been used to enhance his sentence for a subsequent offense. After review, the Court of Criminal Appeals held that an appellant may not reap the benefit of an illegally lenient sentence and then, once he has discharged that sentence, invoke the illegal lenity in an attempt to prohibit the use of that conviction to enhance the sentence for a subsequent offense. View "Deen v. Texas" on Justia Law

Kelvin Roy was convicted of murder and sentenced to seventy-five years’ imprisonment. The trial judge denied his request for a jury instruction on the lesser-included offense of manslaughter. Because there was “more than a scintilla” of evidence that would allow a jury to rationally find that if Roy was guilty, he was guilty of only manslaughter, the Court of Criminal Appeals reversed the court of appeals’ judgment affirming the trial judge’s ruling and remanded for a harm analysis. View "Roy v. Texas" on Justia Law

The issue in this case was whether there was sufficient evidence to affirm the jury’s deadly-weapon finding elevating robbery to aggravated robbery. Because the Court of Criminal Appeals concluded that there was and that the court of appeals erred to hold otherwise, it reversed the lower court’s judgment and remanded this case for consideration of Appellant’s remaining points of error. View "Johnson v. Texas" on Justia Law

Appellant William White was convicted for delivery of less than a gram of methamphetamine in a drug free zone, a third degree felony. His punishment was enhanced with a prior felony to a second degree felony, and the trial court assessed his sentence at fifteen years’ confinement in the penitentiary. On appeal, he argued the evidence was insufficient to support his conviction because it failed to establish that he knew he was in a drug free zone when he sold the methamphetamine. The court of appeals rejected this contention, holding that the statute did not require proof that a defendant had such an awareness. The Court of Criminal Appeals granted Appellant’s petition for discretionary review in order to examine this construction of the statutes in question, and finding no reversible error in the court of appeals’ judgment, affirmed. View "White v. Texas" on Justia Law

Pleading guilty to the offense of sexual assault in 1984, Appellant Milton Crawford was convicted and later required to register as a sex offender. Twice after that, in 2007 and then again in 2009, he was convicted of the felony offense of failing to comply with sex-offender-registration requirements. In 2013, he was once again indicted for failing to comply with sex-offender- registration requirements, a third degree felony. Moreover, the 2013 indictment alleged the two previous felony sex-offender-registration offenses in enhancement paragraphs, to bring Appellant within the ambit of Section 12.42(d) of the Penal Code and thereby raise his exposure to a term of life, or not more than 99 years or less than 25 years, in the penitentiary. Appellant objected to the application of Section 12.42(d) to enhance his punishment, but nevertheless pled true to the enhancement paragraphs. A jury found them to be true and assessed his punishment at a term of 85 years in the penitentiary. On appeal, Appellant again challenged the legality of his enhanced sentence. He argued that the State could not use prior felony offenses for failure to comply with sex offender-registration requirements to punish him as a habitual felony offender for a subsequent sex-offender-registration offense under Section 12.42(d) of the Penal Code. The Court of Criminal Appeals granted Appellant’s petition for discretionary review in order to review his contention that the court of appeals erred to hold that the State could invoke Section 12.42(d) to punish him as a habitual offender. After review, the Court disagreed with Appellant’s contentions and affirmed the court of appeals. View "Crawford v. Texas" on Justia Law

Appellant Jennifer Wolfe presented an issue of whether expert testimony on the subject of abusive head trauma was reliable. She raised the issue in her petition for discretionary review following her conviction in a bench trial for first-degree-felony injury to a child after an infant under her care sustained serious internal head injuries. Appellant objected to the State’s experts’ testimony on the basis that it was unreliable, but the trial court overruled her objection. On discretionary review, appellant challenged the court of appeals’ ruling upholding the admissibility of this evidence on two bases: (1) the court of appeals erred by concluding that the experts’ testimony on abusive head trauma “based solely on a constellation of symptoms” was sufficiently reliable so as to render it admissible under the rules of evidence; and (2) the court of appeals incorrectly determined that her appellate challenge to the reliability of the experts’ testimony on abusive head trauma did not fairly include the issue of whether the expert testimony was unreliable “given this specific injured party’s history.” With respect to appellant’s contention challenging the reliability of the experts’ testimony of abusive head trauma based solely on a constellation of symptoms, the Court of Criminal Appeals agreed with the court of appeals’ assessment that the experts’ testimony was sufficiently reliable so as to warrant a conclusion that the trial court did not abuse its discretion by admitting that evidence, and thus overruled appellant’s complaint as to this matter. With respect to appellant’s contention that the court of appeals erred by declining to consider this particular complainant’s history in conducting its reliability analysis, the Court concluded that the court of appeals’ analysis reflects that it did consider whether the experts’ opinions were reliable in light of this complainant’s particular injuries. Further, to the extent that appellant complains that the court of appeals improperly declined to consider the complainant’s medical history of prior bleeding in the brain as a basis for rejecting the reliability of the State’s experts’ testimony, the Court concluded that appellant did not rely on the complainant’s history of prior bleeding as a basis for arguing that the experts’ opinions were unreliable, and thus the court of appeals did not err by declining to address that issue. Finding no reversible error, the court of appeals’ judgment upholding appellant’s conviction was affirmed. View "Wolfe v. Texas" on Justia Law

A jury found appellant Rodney Lake guilty of sexual assault of a child under age seventeen and sentenced him to ten years in prison and a $10,000 fine. Upon the recommendation of the jury, sentence was suspended and appellant was placed on community supervision for ten years. The issue this case presented for the Court of Criminal Appeals' review was whether the denial of closing argument at a community-supervision revocation proceeding was the sort of error that was exempt from a harm analysis. The Court concluded that it was not, because the Supreme Court has not labeled it as structural. Consequently, the Court reversed the judgment of the court of appeals and remanded the case for a harm analysis View "Lake v. Texas" on Justia Law

Appellant Angel Obella entered a guilty plea to aggravated sexual assault and was sentenced by the trial court to 30 years’ imprisonment. Appellant filed a motion for new trial alleging that his plea was involuntary based on ineffective assistance of counsel, and requesting that the motion be set for a hearing. Appellant attached affidavits in support of his allegations. The State filed a response to the motion and attached an affidavit of appellant’s trial counsel. The trial court did not hold a hearing and the motion was overruled by operation of law. Appellant claimed the trial court abused its discretion by not conducting a hearing on his motion for new trial. The State filed a motion for rehearing with the court of appeals, alleging that appellant failed to preserve his new-trial claim because he did not timely “present” the motion to the trial court. The court of appeals denied the State’s motion for rehearing. The State sought review with the Court of Criminal Appeals, claiming in part that the issue of presentment involved an issue of error preservation, that issues involving preservation of error are systemic and should be addressed by the reviewing court on its own motion, and that the court of appeals erred in not deciding the issue of presentment after it was brought to the court’s attention in the State’s motion for rehearing. The Court of Criminal Appeals agreed and reversed. View "Obella v. Texas" on Justia Law

The officer in this case encountered and arrested an intoxicated driver during a traffic stop he initiated to check the welfare of a passenger in the vehicle. The question this case presented for the Court of Criminal Appeals’ review was whether this particular traffic stop was a reasonable seizure under the community-caretaking doctrine. The Court held that it was. View "Byram v. Texas" on Justia Law

Appellant Jeffrey Pruett was convicted of arson, and the jury made a deadly-weapon finding. The question before the Court of criminal Appeals was whether: the fire started by appellant was a deadly weapon when the fire was started with an accelerant in a residential neighborhood; was left unattended and uncontrolled by appellant; and was ultimately extinguished through the efforts of appellant’s neighbors and the Fort Worth Fire Department. Because the record supported a finding that the fire was capable of causing death or serious bodily injury, the Court held that the deadly-weapon finding was proper. Consequently, the Court reversed the judgment of the court of appeals. View "Pruett v. Texas" on Justia Law